K & M La Botica Pharmacy, Incorporated, et al. - Page 22

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               Ahmed treated himself as owner of all of the nominee                   
          entities and freely intermingled their financial and business               
          affairs with his own and without regard to their corporate                  
          status.                                                                     
               Ahmed would pay his personal expenses and expenses of                  
          entities he controlled with funds from his other controlled                 
          entities.  For example, Ahmed used checks written on K & M’s bank           
          account to pay his personal credit card bills and the mortgage              
          and property taxes on his personal residence.  Also, during at              
          least 1995 and 1996, Ahmed cashed checks payable to K & M and               
          diverted the check proceeds to his personal use.                            
               Employees of the pharmacies, the clinics, and the lab were             
          instructed by Ahmed to leave in Ahmed’s office at night cash                
          sales proceeds of the pharmacies, the clinics, and the lab.                 
          Ahmed then would deposit only a portion of the cash sales                   
          proceeds into the bank accounts of his nominee entities, and                
          Ahmed would divert the undeposited cash to his own personal use.            
               Ahmed engaged in “churning” lab managers.  Ahmed would                 
          attract new managers to the lab by promising them above-market              
          salaries.  Ahmed would not pay the new managers, and when they              
          complained, he would fire them.  At least two of the above lab              
          managers were successful in making claims against Ahmed for                 
          unpaid wages.                                                               







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